Web Site: www.dft.gov.uk
Our Ref: F0018879
6th October 2020
Mr Andy Soames
[By email: request-691147-
xxxxxxxx@xxxxxxxxxxxxxx.xxx]
Freedom of Information Act Complaint – F0018879 Dear Mr Soames,
I am replying to your request, received on 22 September, for an internal review of the
department’s response to your FOI request. You originally asked for information relating
to passenger footfall in the last week of August 2020 or another later week, showing a
breakdown of this figure below national level.
The Department’s reply dated 21 September confirmed that the information you
requested is available on the departmen
t’s website, and explained the data can only be
presented at national level.
In your request for an internal review you stated that, if the data could only be provided at
national level, then our response should not have suggested the data was already
available. You also challenged our argument that data is not available at sub-national
level.
Your request for a review has been passed to me to deal with, as I had no involvement in
the handling of your original request.
In reaching my decision I have carefully considered your complaint and have sought
further clarification from the officials who handled your original request.
Findings
The original answer that stated the information was held referred to the National Rail
usage figure already published through the weekly
Department for Transport coronavirus
transport usage statistics. As you noted, this was not the question you were asking, which
you clarified in your request for an internal review. I agree that the original reply was
wrong to say the information requested was readily available.
The data requested comes from the Lennon database (Latest Earnings Networked
Nationally Overnight) and can be accessed by the department. Lennon is the Revenue
settlement service that Train Operating Companies (TOCs) use to track passenger rail
ticket sales in Great Britain, and the main source of data on rail fares revenue in the
region. The system processes information from all Great Britain train ticket sales, and
allocates daily revenue accordingly, to TOCs and third parties (such as travel agents or
online ticket sellers), as well as origin and destination stations.
Lennon does not categorise data based on easily recognisable geographical locations,
such as “England”, “Scotland” or “Wales”, Government office regions or even individual
counties. Instead, Lennon groups stations into zones, with “primary zones”, the highest
level of disaggregation, based on historic rail operational areas.
The Lennon system is owned and maintained by the Rail Delivery Group (RDG), and data
is made available to the department under a licence agreement. The data is considered
commercially confidential and the department’s licence agreement does not allow for the
publication of any information extracted from Lennon.
Recently, RDG allowed the department to publish certain national-level information to
assist in monitoring COVID-19. Requests to release more disaggregated information from
Lennon have, however, been refused, as any further disaggregation would reach the
commercial confidential level of the data.
This review, therefore, has found that the information should be withheld under Section
41(1) of the FOI Act, to reflect the commercial confidentiality of the information.
Summary
After taking everything into consideration, I concluded that the original answer was
incorrect in signposting the national-level data already published, but correctly withheld
the information. The exemption under which this data is withheld is Section 41(1) –
Information provided in confidence.
Next Steps
If you are not content with the outcome of this internal review, you have the right to apply
directly to the Information Commissioner for a decision. The Information Commissioner
can be contacted at:
https://ico.org.uk/make-a-complaint/official-information-concerns-
report/official-information-concern/ Yours sincerely
Ian Knowles
Deputy Director, Analytics and Data Division,
Department for Transport